Privacy Policy

Effective from: January 1st, 2021
Database reviewed and updated: quarterly

Open Way Listening is proudly committed to complying with the Data Protection Acts 1988 and 2003 and SI 336 of 2011 EUROPEAN COMMUNITIES (ELECTRONIC COMMUNICATIONS NETWORKS AND SERVICES) (PRIVACY AND ELECTRONIC COMMUNICATIONS) REGULATIONS 2011 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) which replaces the previous data protection directive (officially Directive 95/46/EC) on May 25th 2018 (“Data Protection Legislation”).

By visiting the openwaylistening.com website, or by agreeing for your business and services to be advertised in any form on my website, you are accepting the terms of this Privacy Policy. Any external links to other website are clearly identifiable as such, and I am not responsible for the content or the privacy policies of these other website.

General information

This privacy policy (the “Policy”) refers to the website, [ https://openwaylistening.com/] (the “Website”). The Website is operated by Natalie Sowinska (“I”, “me”, “my”) whose principal place of business is at

Address

The Policy explains how I use any personal data I collect about you (either “user” or “service provider”) when you use the Website. This Policy is designed to protect you, users, by informing you what personal data is collected, how I will use the information about you, with whom I share it, how long I keep it and how to contact me if you have any queries or concerns about the use of your personal information.

Your use of the Website and any micro-sites is subject to your agreement with this Policy. In this Policy, the term “personal data” or “personal information” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, my possession, and includes personal data as described in Data Protection Legislation (as defined below).

Please read the following carefully. Entering into this Website and providing your consent to my use of your personal data in accordance with the terms of this Policy indicates that the user has reviewed this Policy and has agreed to be bound by it. If you no longer consent to my processing of your personal data, you may request that I cease such processing by contacting me via this page.

Cookies

Openwaylistening.com website uses native and third party cookies.

A cookie is a little piece of text stored by the browser on your computer, at the request of my server. Cookies may be used to deliver specific information to the interests of users and to save personal preferences.No personal information is recorded, and the cookie can always be deleted or declined using browser setting.

Purpose of data collection

The non-personal data gathered from visitors to my website is used to get a better understanding of website traffic as well as to better design and organise my website.
1.3.2

What data do I collect?

  • Email address
  • Names
  • IP addresses
  • Location

I will collect, store and process information about you if you voluntarily provide me with such information in connection with the following:

  • Book an appointment with me
  • Use my services
  • Contact me

Who I share your data with

I do not sell, otherwise disclose, or share data I collect and hold about you, except as described in this Privacy Policy.

I may share your personal data with third parties as described below:

  • If you use booking service provided, your data may be shared with third party responsible for technical development and support of the system,
  • If you use payment gateway provided, your data will be captured by third parties: PayPal and relevant credit card provider, which have their own policies,
  • If I am required to do so by law or pursuant to legal process or to comply with any applicable rules or regulations, or in response to a legitimate request from a law enforcement authority or other government official,
  • I reserve the right to transfer personal data about you in the event that I sell or transfer all or a portion of my business or assets, in accordance with applicable law. Should such a sale or transfer occur, I will use reasonable efforts to direct the transferee to use data you have provided to me in a manner that is consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which I transferred your data with any inquiries concerning the processing of that data.

Disclosure of information

You will never be contacted via phone or messenger at any time other than for pre-arranged sessions. Your telephone number, messenger ID or email address will not be shared with any outside agencies or third parties. If you request a free E-book you will not receive unsolicited emails, your email address will not be saved. If you sign up to the newsletter, your email address will not be shared.

Information which will not be provided

I will not normally disclose the following types of information in response to a Data Access Request:

(a) Information about other People
A Data Access Request may cover information which relates to one or more people other than the Data Subject. The information about the other person may be Personal Data about that person, to which the usual data protection rules under the Data Protection Acts, including the restrictions on disclosure, apply. In such circumstances I will not grant access to the information in question unless either: (i) the other person has consented to the disclosure of their data to the Data Subject or (ii) in all the circumstances it is reasonable to make the disclosure without that person’s consent. If the person’s consent is not forthcoming and it is not reasonable to make the disclosure without consent, I will make available as much Personal Data as I can without revealing the identity of the other person (for example by excluding the person’s name and/or other identifying particulars).

(b) Opinions given in Confidence
Where I hold Personal Data about the Data Subject in the form of an opinion given in confidence I am not required to disclose such opinions in response a Data Access Request in all cases.

(c) Repeat Requests
The Data Protection Acts provide an exception for repeat requests where an identical or similar request has been complied with in relation to the same Data Subject within a reasonable prior period. I will consider that if a further request is made within a period of six months of the original request and where there has been no significant change in the personal data held in relation to the individual, it will be treated as a repeat request.

Accordingly, where Personal Data has recently been provided to the Data Subject or his/her legal representative, I will not normally provide a further copy of the same data in response to a Data Access Request. I will not consider that I am obliged to provide copies of documents that are in the public domain.

(d) Privileged Documents
Where a claim of privilege could be maintained in proceedings in a court in relation to communications between an individual and his or her professional legal advisers (or between those advisers) any privileged information which I hold need not be disclosed pursuant to a Data Access Request. Where I refuse a Data Access Request, I will do so in writing and will set out the reasons for refusal. Any person who is dissatisfied with the response to their request has the right to make a complaint to the Data Protection Commissioner.

How long do I retain your data

There is no definite amount of time for which I will be storing any sensitive information.

For users that register on the website (if any), I also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

You have rights to access, update or request an erasure of your data.

Please be aware that in some cases erasure can make impossible to provide my service to you. In accordance with Data Protection Legislation, request of data erase can be made in case that:

  • user/ service provider does not believe that I need their personal data in order to process it for the purposes set out in this Policy;
  • if user or service provider had given me consent to process your personal data, you withdraw that consent and I cannot otherwise legally process your personal data;
  • user or service provider objects to my processing and I do not have any legal basis for continuing to process your personal data;
  • data has been processed unlawfully or have not been erased when it should have been; or
  • the personal data must be erased to comply with law.

Financial information

I do not request proof of income or financial status, discounts are available to all. I do not request banking and financial information, no card payments are taken via the phone. Purchases for counselling sessions are made securely via the PayPal payment gateway. You can check your purchase history with them directly, they generally send email receipts after each purchase. You may also wish to view transactions by logging into your PayPal account if you have one.

I do not store, collect or even have access to your passwords and bank account details or any other information stored and processed by third party payment gateway provider.

Media

Media used on the website come from three sources:

  • Public domain (stock images)
  • Owned by me
  • Media provided by the owner of copyrights for marketing or community purposes

External links

My site may contain links to and from other websites. If you follow a link to any of these websites, please note that they have their own privacy policies and that I do not accept any responsibility or liability for those policies. Please check their policies and terms of use before you submit any personal data.

Comments

If you would like to leave a comment under a blog post, you are required to provide a name and email address. This can be further used to contact you with marketing offers. Comments are reviewed before publishing and can be changed if contain inappropriate or explicit language. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

2. Social Media Privacy Policy and Statement

2.1 Instagram Policy

2.1.1 The @Openwaylistening Instagram account is managed by the person responsible for Openwaylistening IT and communications. Posts from this account will cover developments in Openwaylistening and related services. If you follow me, you can expect posts covering some or all of the following:

  • Press Releases
  • Event information;
  • Marketing campaigns
  • Alerts about new content on the website;
  • Other practical information relevant to Openwaylistening and psychology

2.1.2 Instagram may occasionally be unavailable, and I accept no responsibility for this lack of service. Posts may be used to highlight relevant appropriate announcements, particularly those by other Government bodies and neighbouring councils.

2.1.3 Normally my Instagram account will be updated and monitored during office hours, Monday to Friday. I welcome and will read all @ messages. However, in general, due to resource constraints, I will not be in a position to reply to all messages.

2.1.4  I will not be obliged to follow any of my followers. If I do follow an Instagram account, it does not imply endorsement of any kind.

2.1.5 Sending a message via Posts will not be considered as contacting me for official purposes and I will not be obliged to monitor or respond to requests for information through the Instagram channel.

2.1.6 Please do not include personal/private information in your posts and comments. Openwaylistening is not responsible, liable for and does not endorse the privacy practices of posts and comments or any linked websites. Your use of Instagram and any linked websites is at your own risk.

2.1.7 Openwaylistening assumes no responsibility or liability for any injury, loss or damage incurred as a result of any use or reliance upon the information and material contained within or downloaded from these websites.

2.2 Facebook Policy

2.2.1 This policy outlines participation criteria for postings and published commentary on the Openwaylistening Facebook page.

2.2.2 The Openwaylistening Facebook page intends to provide information and updates regarding providers of the services related to tourism, public and social festival and events.

2.2.3 In order to ensure that all discussions on the Openwaylistening page are productive, respectful, energized and consistent with my mission and goals, I ask you to follow these guidelines:

  • Be considerate and respectful of others. Vulgarity, threats or abuse of language will not be tolerated;
  • Differing opinions and discussion of diverse ideas are encouraged, but personal attacks on anyone, including staff, will not be permitted;
  • Share freely and be generous but be aware of copyright laws; be accurate and give credit where credit is due;
  • Stay on topic;
  • Refrain from using the Facebook page for solicitation, for commercial purposes or to market products;
  • The sites are not monitored 24/7 and I will not always be able to reply individually to all messages or comments received. However, I will endeavor to ensure that any emerging themes or helpful suggestions are passed to the relevant people.

2.2.4 Sending a message/post via Facebook will not be considered as contacting me for official purposes and I will not be obliged to monitor or respond to requests for information through the Facebook channel.

2.2.5 I retain the right to remove comments or content that includes:

  • Obscene or racist content;
  • Personal attacks, insults, or threatening language;
  • Potentially libelous statements;
  • Plagiarized material; any material in violation of any laws, including copyright;
  • Private, personal information published without consent;
  • Information or links unrelated to the content of the forum;
  • Commercial promotions or spam.
  • 2.2.6 I am not responsible for the accuracy of content posted by any subscriber in any forum; opinions expressed in comments on my social media forums do not necessarily represent those of mine.

2.2.7 All comments, once posted, become the property of Openwaylistening and I reserve the right to reproduce, distribute, publish, display or edit same. Derivative work also can be created from such postings or content, and used for any purpose, in any form and on any media.

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